Why Do Some Products Have an Irish Address on Them?

A good question from a recent customer in one of our shops in Edinburgh, and it’s one that deserves a proper answer. If you've ever wondered why some of our products carry an Irish address, it all comes down to an important but rather overlooked part of the cosmetics world: the Responsible Person (RP). 

It’s not just an arbitrary rule or a bit of red tape to make life more complicated, although it sometimes feels like it. 

In both the UK and the EU, having a Responsible Person is a legal requirement for any company selling cosmetics. It’s not just for businesses operating at home either, if you want to export, particularly to the EU, you need to have one. 

Why does this matter? First off, it’s all about regulatory compliance. The UK has its own cosmetics laws, adapted from the EU’s original regulations after Brexit. But the EU still follows the same set of rules, and if you want to sell within the single market, you need an EU-based Responsible Person. It’s the same story in many other countries too, most have their own version of this requirement, making it a crucial part of doing business internationally. Our RP is based in Ireland, and they’re the same company who carry out our safety assessments. As we have many customers in the EU, it means we can supply them without fear of legal repercussions. 

It’s not just a bureaucratic box-ticking exercise. The RP plays a critical role in consumer safety and product liability. Each product recipe has to go through rigorous safety assessments, including toxicological checks, ingredient restrictions, and labelling requirements. If there’s ever a safety concern or a customer complaint, the RP is the official point of contact for regulatory authorities. They handle investigations, recalls, and anything else that might arise. It’s a lot of work for us but it means we can operate safe in the knowledge that we’re operating within the letter of the law. 

Then there’s the issue of product registration and legal representation. Before any new cosmetic product can be sold in the UK, it has to be registered with the Submit Cosmetic Product Notification (SCNP) database. In the EU, it has to go through the Cosmetic Products Notification Portal (CPNP). Other markets have their own systems in place, and most will require some form of legal representation to ensure full compliance. Still thinking about starting that soap business? I actually know of a few cosmetics businesses who simply gave up rather than face the challenge of the mountain of paperwork and the costs involved. 

The RP is also responsible for labelling and documentation. That means making sure ingredient lists, product claims, and packaging all meet national legal standards. They also maintain a Product Information File (PIF), which contains everything from safety assessments to formulation details and proof of compliance. This is a particularly useful service as the exact labelling requirements are provided to us by our RP. It’s the easiest thing in the world to make errors when drafting a product label. I’ve seen many, many examples of poorly labelled products, even on the products of big, well established brands. 

What happens if a company tries to sidestep all of this? Many companies do but the consequences can be serious. Selling cosmetics without an RP in a regulated market can result in fines, product bans, or even forced recalls…nightmare! Retailers and distributors might also refuse to stock a product if there isn’t an RP in place, making it impossible to get products onto shelves. 

It’s not just the UK and EU where this applies. Many other countries have similar rules. The US FDA has its own regulations but doesn’t mandate an RP. China requires foreign cosmetics to be registered, often with a local representative. Countries like Canada, Australia, and those in the Middle East all have their own versions of these legal requirements too. We sell a lot in Japan and our partner over there had to get all of our products individually registered with the Japanese authorities who, by the way, are the most stringent in the world when it comes to regulatory requirements and quality control. 

So, in short, the reason some of our products have an Irish address is simple: it’s a legal necessity. The RP system exists to protect consumers, ensure product safety, and keep everything above board. If you want to sell internationally, you either appoint local representatives or work with compliance services to meet each country’s regulations. No shortcuts, no way around it, it’s just the way the industry works. 

If you had the patience to read through this, I salute you! 

If you have any questions you’d like to ask, please do. 
 
Tommy Crooks: The Founder.